Policy ENV4 - Canals

Support

Representation ID: 1236

Received: 08/09/2017

Respondent: Canal & River Trust

ENV4 - Canals
Introduction
The Issues and Options Report proposes that the overall approach set out in Policy ENV4 remain unchanged but that references to specific canal schemes could be removed.
In brief, the Trust welcomes the recognition of the benefits of the current policy in the Issues and Options Report and confirmation that the policy remains appropriate but considers that the existing policy would benefit from additional refence to some of the wider opportunities provided by a waterside location, as detailed below. The Trust does not consider that reference to specific canal projects should be deleted from the Strategy and would recommend that the supporting text be amended to include reference to other such projects currently underway in the Back Country.

Background
Paragraph 156 of the NPPF states that the strategic priorities for the area should be set out within the Local Plan. These should include strategic policies to deliver on areas such as leisure development, provision of health, community and cultural infrastructure and conservation and enhancement of the natural and historic environment, including landscape.

Paragraph 178 of the NPPF identifies that public bodies have a duty to cooperate on planning issues that cross administrative boundaries, particularly those which relate to the strategic priorities.

The existing Black Country Core Strategy states that it is visionary and transformational, setting out how the Black Country should look in to the future and establishing clear directions for change in order to achieve this transformation. This is further emphasised in the current consultation document which states, 'The Core Strategy is a key part of the Local Plan for the Black Country Authorities forming the overarching planning and regeneration document for the whole of the area.'

The waterways span several local authority boundaries and it is therefore important to ensure that there is a clear and consistent strategic policy approach to development that affects existing waterways or proposals for restoration.

Canals have played a significant part in the development of the Black Country and continue to do so. They are multi-functional assets providing multiple economic, social and environmental benefits. In addition to being a source of green and blue infrastructure, important for their heritage value and leisure, recreation and tourism uses, they can provide local and strategic sustainable transport routes, and are increasingly being used in association with new technologies, contributing to the creation of 'Information Superhighways' and are a potential source for thermal energy generation and cooling. They can act as catalysts for regeneration and a focus for development, vital for many local small or medium sized enterprises (SMEs) whilst also supporting and adding value to larger companies. They form a valuable part of the nation's visitor and green economies - engaging local communities and visitors alike and laying the foundations for future health, well-being and prosperity.

It is therefore vitally important that planning policy recognises the multi-functional nature of waterways and the contribution they can make to wider economic and social objectives such as public health, renewable energy and sustainable development, future proofing our urban areas by strengthening their resilience and creating conditions suitable for growth.



Policy Wording
The Trust welcomes the recognition of the benefits of the current policy in the Issues and Options Report and confirmation that the policy remains appropriate. It is however considered that the existing policy would benefit from additional refence to some of the wider opportunities provided by a waterside location, such as:

* Health and Wellbeing: waterways have a significant role to play, particularly in tackling physical inactivity, obesity and reducing stress in the many disadvantaged communities with waterways on their doorstep. Evidence suggests that simply being near to water makes people more content and relaxed and over half the UK population lives within five miles of a canal or river. Within the Black Country 70% of the population live within 1km of the canal. It should be recognised that underperforming waterways and areas of market failure and high deprivation quite often go hand in hand. Over the last twenty years, waterways have been both the catalyst and the focus for an immense amount of regeneration and development which has acted to build developer and investor confidence, particularly in disadvantaged areas, contributing to social inclusion. Waterways and towpaths provide a range of outdoor space for cultural, civic, learning and community activity and local heritage. With waterways on many disadvantaged local communities' doorsteps they have an important role to play in skills development and youth social action. Learning outside the classroom is proven to tackle social mobility and be of particular help to young people from disadvantaged backgrounds, increasing self-esteem, raising levels of attainment and improving mental health and wellbeing

* Infrastructure provision, for example digital technology, fibre optic networks, etc in towpath: With the increasing importance of digital connectivity the waterways provide established corridors through the heart of urban areas with the potential to accommodate infrastructure with relatively little disturbance in comparison to, for example, digging up main roads and pavements in busy locations. There is a real opportunity to maximise the use of the Trusts existing fibre optic networks and the canal corridor and Trusts land holdings for the provision of new and improved infrastructure around densely populated areas, such as the routing of infrastructure for district heating schemes and increasing mobile cell density to create 4G and 5G towns and cities.


Sustainable Energy Source for heating and cooling:
The potential for inland waterways to contribute to the low carbon economy and build resilience should also consider new energy technologies such as biomass capacity, and the identification of waste streams such as from the operation and maintenance of waterway management for recycling, reuse and energy from waste markets.
The canal network provides readily available opportunities for developments to incorporate innovative technologies to make use of its water such as the abstraction of canal water for cooling purposes and/or for heating purposes where there is a sufficient flow of water to sustain this use and the canal towpath for the running of pipelines etc. which need to be more greatly encouraged.
The water flowing through the Trust's waterways which pass through most major cities in England contains enough thermal energy to produce approximately 640 MW of energy. This has attracted a number of businesses which now utilise this low carbon source to heat and cool their buildings. DECC too have acknowledged this potential in their Heat Map which includes a specific canal layer. The energy is extracted using water sourced heat pumps which are very efficient compared to conventional forms of heating and cooling. These efficiency improvements will help reduce the electricity demand and assist in balancing electricity supply.

* Reducing Flood Risk to Development
The waterway network presents a number of opportunities to support and enhance urban development, with particular reference to water management. Water levels in the canal network are managed by the Trust using control structures such as weirs and sluices to maintain a suitable depth for navigation by boats, but also to try to avoid water levels becoming too high in periods of heavy rainfall where runoff from hard surfaces can lead to excess water passing into the canals. With careful design and assessment, canals may be able to receive runoff from future development sites, providing sustainable options for site drainage (although mitigation works to the canal infrastructure may be necessary to cope with this.) This may allow development of sites that would otherwise not be viable due to flood risk concerns with alternative site drainage options. The ability of canals to accept surface water run-off may also assist in wider consideration of flood mitigation measures given the managed nature of canal water levels.

The Trust would welcome the opportunity to work with you on any amended wording to Policy ENV4.


Supporting Text and Specific Projects
The Trust does not support the removal of the reference to canal projects from the Strategy.
The current Core Strategy states:
'The Black Country's canal network is one of its most defining historical and environmental assets and the preservation and enhancement is a major objective in the Vision for environmental transformation and the delivery of Spatial Objective 6.

Spatial objective 6 - high quality environment fit for the future, and a strong Urban Park focussed on beacons, corridors and communities; respecting, protecting and enhancing the unique biodiversity and geodiversity of the Black Country and making the most of its assets whilst valuing its local character and industrial legacy.'
The canal projects are a key part of the enhancement of the canal network and therefore a major objective in the vision and delivery of Spatial objective 6 of the Core Strategy which should be continued.

Canal restoration projects have a number of benefits for a local community and can be a catalyst for redevelopment and regeneration. In addition to the environmental benefits, as identified above, canal restoration can also have positive economic and social impacts and therefore aid in achieving other key objectives of the Core Strategy.
Para 6.18 &19 of the Core Strategy further outline the importance of canal projects and, with particular reference to the Hatherton Branch Canal, confirms support for canal restoration as 'a strategic addition to the region's canal network.'

Canal projects are typically strategic, cross boundary proposals and as such more appropriate for inclusion in an overarching strategic policy document such as the Core Strategy than left to individual Local Plans where inconsistency of approach may be an issue

Policy ENV4 states only that "Development will not be permitted which would sever the route of a disused canal or prevent the restoration of a canal link where there is a realistic possibility of restoration, wholly or in part." Canals and the line of the disused Hatherton Branch Canal are identified on the Black Country Core Strategy Key Diagram. The policy is therefore seeking only to safeguard the line of the restorations. It is not allocating the line as a completed/connected waterway nor does it indicate a presumption in favour of any future planning application for such as use, which would be subject to the usual statutory planning and other processes, including HRA. Such an approach is considered both desirable for the protection of the line of the former canal and wholly appropriate.
The supporting justification to Policy ENV4 explains progress to date in respect of the restoration of the Hatherton Canal and, notwithstanding delays caused by past/present economic conditions, the importance of safeguarding the route in the longer term. Again, such an approach is considered wholly appropriate and necessary to support the wording of Policy ENV4.
Consideration should also be given to including reference to other canal projects in the Black Country in the supporting justification to policy ENV4.
The supporting text currently identifies the proposals to restore the Hatherton Canal. There are however other restorations within the area. Whilst the restoration projects are at different stages feasibility studies have been undertaken and many are well established with progress being made since the adoption of the Core Strategy.
- Hatherton Canal (http://www.lhcrt.org.uk/arup.htm)
- Bradley Arm (https://www.waterways.org.uk/waterways/restoration/restoration_resources/portal/pd fs/bradley_locks_feasibility_study)
- Lapal Canal (http://www.lapalcanal.co.uk/membership-matters/)
- Stourbridge Canal (Fens Branch)

The feasibility study for the Bradley Arm was completed in 2015 and makes specific reference to Policy ENV4. The site spans 3no. Local Authorities and Section 3 of the Study highlights the complexities that can be involved with such cross-boundary proposals. The fact that all of 3no. Authorities involved share the Black Country Core Strategy as their strategic statutory document is seen as 'highly important'.
The Annual Monitoring Reports for each individual Authority within the Black Country indicate that overall Policy ENV4 is working well though this focuses on development management. The references within the Bradley Arm feasibility study highlights that the policy is also working in enabling these projects to move forward and should therefore be retained.

The following amendments are therefore recommended to the supporting text:
"6.19 There are a number of canal restoration projects within the Black Country which cross administrative boundaries:
- Hatherton Canal
- Bradley Arm
- Lapal Canal
- Stourbridge Canal (Fens Branch)

It is important that these schemes, and any future schemes that may come forward, are supported as important strategic additions to the region's canal network."